The following four intra-BRICS DTCs are substantially the same with taxation in both the source and residence (except for the Russian DTC) country together with the PE and non-arm’s length articles.
AT is levied in EU Member States and is subject to harmonised rules under increasing EU legislation in this area. GST, on the other hand, is a term used by many jurisdictions (eg Pakistan, Australia and Singapore), but describes a different tax or levy depending on the actual jurisdiction.
Sylvia H. Torres Caro analyses the concept, advantages and disadvantages of legal stability agreements and double tax treaties in attracting foreign investment, with particular reference to Colombia.
In general, direct tax matters still fall within the competence of the member states. Tax measures at community level can only be established by unanimity. However, that direct tax competence must be exercised consistently with community law. This interaction can create tensions between on the one hand the interests of member states and on the other hand the objectives of the EU.
It should be stated at the outset that this article is not a religious or economic discussion on the topic of Islam and Islamic Finance, nor is it meant to discuss any of the ethical or political issues surrounding these topics.
International tax avoidance using trusts: How can Cyprus facilitate this form of tax planning?– Part II
In Part I, Iva Angelova introduced the concept of tax avoidance and explained how trusts are used in tax planning schemes. In Part II, she continues with a discussion on the use of trusts internationally and the role played by Cyprus in the world of tax planning.
In Part I, Grahame Turner examined the relationship between two justifications found in the direct tax jurisprudence of the ECJ, namely, “coherence of the tax system” and “balanced allocation of taxing powers”. In Part II, he continues his analysis.
The UN Model Tax Convention and the taxation of inter-company dividends in treaties between developing countries and the G8
Jonas Bley provides analysis of recent research into the influence of tax treaties on foreign direct investment into developing countries
Investment and Indirect Taxes
In Part I, Sylvia H. Torres Caro discussed how Colombia attracts foreign investment and focused her discussion on legal stability agreements put in place by Colombia and other Latin American countries. She concluded by briefly discussing the role played by Colombia’s double tax treaties in securing foreign direct investment. Part II continues this discussion.
International tax avoidance using trusts: How can Cyprus facilitate this form of tax planning? – Part 1
It is evident that at an international level tax planning nowadays is a reality. The purpose of this article is to provide an analysis of how international tax avoidance in the sense of legal minimisation of tax liability can be achieved by the potential use of international trusts. By choosing the correct jurisdiction this practice can prove to be beneficial to all parties and an overview of the advantageous stance Cyprus can have on this matter will be demonstrated.
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